The Questions

Question 1:BEPS: Mid-Year Review : What have been the principal ‘Pillar 1 & Pillar 2’ developments in the first half of 2022 and do you envisage the timeline for the rules to come into force changing?

Question 2: Debt vs Equity finance : Can you please outline the tax advantages of using debt finance over equity finance? How is the EU's DEBRA directive attempting to level the playing field in this regard?.

Question 3: BEPS & International Financial Services : BEPS: What are the potential tax implications for International Banking in Ireland as a result of the changes being brought about by the OECD’s BEPS project?

Question 4: Tax Appeals Commission: Tax Appeals Commission: Can you please comment on the most noteworthy determinations made by the Tax Appeals Commission during the second quarter of 2022?

Question 5: Technology : ‘Tax Tech’: What in your view are the main tax tech issues that will need to be addressed by large corporate CFOs in Ireland in the coming years?

Question 6: Ireland's Tax Treaty Policy: The Department of Finance recently outlined its Tax Treaty priorities and plans in a policy published on 27th June. Ireland's longstanding tax treaty policy has been to expand, maintain and enhance its tax treaty network, in order to remove barriers and facilitate trade and investment opportunities between Ireland and partner countries. Can you please explain how Double Taxation Treaties can encourage trade and activity between countries and comment on Ireland's Tax Treaty Policy Statement? (You can view the Statement here.)

Question 7: Wildcard : Optional ‘Wildcard’ Question

Tax Treaties; BEPS mid-year review; DEBRA; Key TAC cases

In this month’s Irish Tax Monitor Roundtable the panel examines Ireland’s Tax Treaty Policy, which is welcomed as a positive step that can help remove barriers and facilitating trade and investment. The EU’s DEBRA directive, and the relative tax advantages of debt vs equity financing, feature also, as does the impact of BEPS on international banking. Tax technology as well as the latest developments in the implementation of BEPS are outlined, as are two key determinations by the Tax Appeals Commission - on the treatment of loan waivers and on section 811 TCA.

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Expanding and modernising Ireland’s Tax Treaty Network

The Department of Finance’s recently published Tax Treaty Policy asserts that Ireland’s Double Taxation Treaty Network remains a key tool for Ireland in promoting trade and investment and will continue to be so when BEPS comes into force. The Tax Treaty policy and when BEPS will be come into force are among the subjects covered in this month’s ITM, as is how BEPS could affect international banking operations, DEBRA, and key new calls by the TAC.

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Transfer Pricing: optimising policies in light of ESG changes to business models

With the increasing influence of ESG strategies on business models it is timely for multinational companies to assess how their Transfer Pricing policies might be adapted or revised to take ESG-influenced business changes into account writes Zarene Viljoen.